Duty of care checklist
20 checks across four stages, from verifying your collector before the first visit through to what your records have to survive. Work down it once, then keep it with your transfer notes.
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Why a checklist rather than a policy
Section 34 of the Environmental Protection Act 1990 does not hand you a list of tasks. It asks whether you took reasonable steps to make sure your waste reached a lawful destination, and leaves you to work out what that means. That ambiguity is fine for a compliance department and useless for a kitchen at half past four on a Friday.
So this is the ambiguity resolved into things you can actually tick. Nothing here goes beyond what the duty of care code of practice expects. If you can honestly tick all 20, you have a defensible position and the evidence to show it.
1 Before the first collection
- Asked the collector for their waste carrier registration number, not a certificate image
- Looked that number up myself on the Environment Agency public register
- Checked the registered name on the register matches the company that invoices me
- Checked the registration is upper tier if they buy the oil rather than only move it
- Checked the registration has not expired
- Saved a screenshot or dated note of that check
2 Storing the oil
- Oil is cooled before it goes into the container
- Containers are sealed, in sound condition and not overfilled
- Stored on a hard surface, away from drains and surface water
- Stored where it cannot be reached by the public or knocked over in a walkway
- Nothing else goes in: no water, cleaning chemicals, food waste or fryer debris
- Nothing ever goes down a sink or drain
3 Every collection
- A waste transfer note is completed and signed by both parties
- The note carries EWC code 20 01 25 and a real measured quantity
- The quantity on the note matches the quantity I was paid on
- My copy is filed the same day, not left in the van or on the counter
4 Your records
- Every transfer note kept for at least two years
- Records retrievable within a few minutes if an officer asks today
- Season ticket, if used, does not run longer than twelve months
- A named person in the business knows where all of this lives
Where kitchens usually come unstuck
"Fully licensed" is not a registration number
The check is not that a collector says they are licensed. It is that you looked up their number yourself and it matched. A certificate photographed and sent on WhatsApp proves nothing at all: it can be expired, edited or somebody else's.
Lower tier for a buyer
A company that buys your oil is dealing in waste, not just moving it, and that needs an upper tier registration as a carrier and dealer. Lower tier is for businesses moving their own waste. It is an easy thing to check and an easy thing to miss.
Storage next to a drain
The most common physical failing, and the most expensive one. A drum by a gully is one knock away from a discharge, and discharging oil to a drain is a separate offence under the Water Industry Act 1991 that sits on top of your duty of care.
Records that exist but cannot be found
Two years of notes in a carrier bag under the till technically satisfies "keep". It does not satisfy "produce on request", which is the other half of the obligation and the half an officer is actually testing when they ask.
Take this and use it
Published under Creative Commons Attribution 4.0 (CC BY 4.0) . Copy it, print it, put it on your own website, adapt it for your borough. The only condition is that you credit London Oil Collection Ltd and link back. No permission needed and no need to tell us, though we would like to hear about it.
Last reviewed 27 July 2026. General guidance on the position in England, not legal advice.
Who this is for
Kitchen owners, managers and anyone preparing for an environmental health visit
Councils, BIDs and environmental health teams: if printed copies would be more useful than a PDF, tell us the borough and a quantity on [email protected] or WhatsApp.